INTERROGATORIES
AND REQUESTS FOR PRODUCTION
OF DOCUMENTS FROM UNITED PARCEL SERVICE
DIRECTED TO THE UNITED STATES POSTAL SERVICE
(UPS/USPS-37 through UPS/USPS-43)
(May 3,200O)
Pursuant to the Commission’s
serves the following interrogatories
to United States Postal Service:
Rules of Practice, United Parcel Service hereby
and requests for production
UPS/USPS-37
of documents
directed
through UPS/USPS-43.
Resoectfullv
submitted,
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John E. McKeever
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
Piper Marbury Rudnick & Wolfe LLP
3400 Two Logan Square
18th & Arch Streets
Philadelphia, PA 19103-2762
(215) 656-3310
(215) 656-3301 (FAX)
and
1200 Nineteenth Street, NW
Washington, DC 20036-2430
(202) 861-3900
Of Counsel.
INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS OF
UNITED PARCEL SERVICE DIRECTED TO UNITED STATES POSTAL SERVICE
UPS/USPS-37.
Provide all quarterly revenue adjustment
factors used in the
RPW System to adjust the DRPW estimates for each quarter of FYI 999. If you cannot
provide this information,
UPS/USPS-38.
explain in detail why.
For each quarter in FY1999, provide (a) the quarterly BRPW
estimates of revenue, pieces, and weight for each of the mail classes or subclasses
for
which BRPW was used to derive estimates of revenue, pieces, and weight, (unadjusted
or true-up to trial balance), (b) the trial balance revenue balances for each unique
account, and (c)the adjustment
factors used for each unique trial balance account.
you cannot provide this information,
UPS/USPS-39.
BRPW revenue, piece, and weight estimates for each of(i)
(ii) Intra-BMC,
(b) FYI999
Inter-BMC,
explain in detail why.
Provide separately:
(a) FYI999
Inter-BMC,
If
and (iii) DBMC Parcel Post.
DRPW revenue, piece, and weight estimates for each of(i)
(ii) Intra-BMC and (iii) DBMC Parcel Post.
(c) FYI999
OMAS and Alaska Bypass Parcel Post estimates.
(d) FYI999
Combined
Enclosure revenue, piece, and weight estimates
for Parcel Post.
UPS/USPS-40.
system, or subsystems
Explain in detail any changes to any part of the RPW process,
for FYI999
versus what was done in FY1998.
were made, explain in detail for each change why it was made.
If any changes
INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS OF
UNITED PARCEL SERVICE DIRECTED TO UNITED STATES POSTAL SERVICE
UPS/USPS-41.
When was a unique trial balance account for BRPW Parcel Post
first set up?
(a)
Was it used to develop the FYI999
BRPW estimates for
(b)
If not, when was it made part of the RPW process?
(c)
If it has not yet been implemented
Parcel Post?
into the RPW process,
explain when it is expected to be implemented.
UPS/USPS-42.
If any adjustment
to the BRPW estimates of revenue,
pieces, and weight for Parcel Post was made in FYI999
pieces, and weight sent at non-automated
to reflect Parcel Post revenue,
offices (similar to the 1.00920754
blow-up
factor used for FY1998), provide the factor that was used to make that adjustment
FYI999
and all supporting
UPSJUSPS-43.
in
documentation.
In the case of each class or subclass of mail for which the
BRPW system was used to derive estimates of revenue, pieces, and weight in FY1999,
provide all of the factors used for Postal Quarters 1 and 4 in FYI 999 to convert the
BRPW estimates from a PFY basis to a GFY basis.
2
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
mail, postage prepaid, in accordance
document
with Section 12 of the Commission’s
by first class
Rules of
c’,J-;4tp-c
Attorney for United Parcel Service
Dated: May 3, 2000.
Philadelphia, Pa.